whether they were likely to be dangerous. DeStefano v. Emergency Housing Group, Inc., 247 F.3d 397 (2d Cir. 2001): Sack, writing for the panel, decided that a state does not violate the Establishment Clause of the First Amendment by providing public funding to a private facility that also offers Alcoholics Anonymous (AA) sessions, which are religious in nature, so long as the staff does not require clients to attend AA sessions. McMenemy v. Rochester, N.Y., 241 F.3d 279 (2d Cir. 2001): Sack, writing for the panel, decided that Title VII of the Civil Rights Act of 1964 renders unlawful retaliation by an employer against an employee who opposes any unlawful employment practice involving any employer, not just the employee's own employer, so long as the employee establishes a causal connection between the retaliation and the employee's protected activity. Commodity Futures Trading Commission v. Vartuli, 228 F.3d 94 (2d Cir. 2000): Sack, writing for the panel, concluded that a seller of an automatic-trading software program that instructs the user when to buy or sell currency futures is a "commodity trading advisor" under the Commodity Exchange Act (CEA), and that the Act, as applied to that seller, did not violate the First Amendment. Awards and honors In May 2008, Judge Sack was awarded the Learned Hand Medal for excellence in federal jurisprudence by the Federal Bar Council. Clerks Judge Sack has been identified as an "academic feeder judge," because a number of his former clerks have entered legal academia. His former clerks include: Hon. Aaron P. Avila (1999–2000), Judge, Environmental Appeals Board Lauren E. Baer (2007–2008), Managing Director, Arena Charles L. Barzun (2005–2006), professor of law, University of Virginia School of Law Pamela Bookman (2006–2007), professor of law, Fordham University School of Law Joshua Block (2005–2006), Senior Staff Attorney, American Civil Liberties Union, LGBT & HIV Project Mala Chaterjee (2019–2020), professor of law, Columbia Law School Robert M. Chesney (1998–1999), Dean, University of Texas at Austin School of Law Jordana Alter Confino (2016–2017), Senior Director of Professionalism & Special Projects, Fordham University School of Law Elizabeth (Lisa) Daniels (2019–2020), Assistant U.S. Attorney, U.S. Attorney's Office, Southern District of New York James Darrow (2008–2009), Assistant Federal Defender, Federal Defenders of New York, Eastern District of New York Meghann E. Donahue (2006–2007), Vice President and Associate General Counsel, Federal Reserve Bank of New York Greer Donley (2017–2018), professor of law, University of Pittsburgh School